October 24, 2017 Megan Ware, Fishery Management Plan Coordinator Atlantic States Marine Fisheries Commission (ASMFC) 1050 North Highland Street, Suite 200 A-N Arlington, Virginia 22201 Re: Menhaden Amendment 3 Dear Ms. Ware, Director Beal, Chairman Ballou, and members of the Menhaden Management Board, As more than 180 organizations, businesses, and individuals representing hundreds of thousands of members, business patrons and communities in every Atlantic state, we support the immediate adoption of ecological reference points in Amendment 3 to the Interstate Fishery Management Plan for Atlantic Menhaden. Specifically, we support Section 2.6 “Option E: BERP Workgroup Continues to Develop Menhaden-Specific ERPs with Interim Use of 75% Target, 40% Threshold.” Atlantic menhaden play a vital role in the marine food web as forage fish that feed a multitude of species including gamefish like striped bass, bluefish, king mackerel, and tarpon; marine mammals such as whales, dolphins, and seals; as well as birds including osprey, bald eagles, common loons, and brown pelicans. As key prey for these and other species, Atlantic menhaden are a critical backbone for our coastal communities, and the many businesses and wildlife-viewing opportunities that they support on and off the water. Managing Atlantic menhaden through Option E prioritizes their role as forage fish, allowing the resource to continue to grow and increase in value to recreational fishing, commercial fishing, and wildlife and tourism businesses. In fact, with over 28 million resident and nonresident wildlife watchers generating over $17 billion for the Atlantic states, ecological management of menhaden can help to drive healthy marine ecosystems as well as robust economies. 1 Amendment 3 should follow the best science available today. Option E represents the best available science and is most consistent with the Menhaden Management Board’s long-standing commitment to ecological management. Option E sets a target of 75% unfished biomass and a threshold of 40% unfished biomass, providing flexibility to the Board to manage to the target over time, while also managing the resource conservatively, combining the best features of Options C and D. Furthermore, Option E sets the Board up for long-term success, allowing for management of this resource towards a target, while limiting the potential of overfishing from an ecosystem perspective. Amendment 3 also presents an opportunity to protect The Chesapeake Bay through a catch cap on the active reduction fishery in those waters. We recommend ASMFC adopt “Option B: Cap Set At 51,000 mt” and “Sub- Option B: No Rollover of Unused Cap Permitted” to adjust the cap to better reflect recent landings, following a precedent set by ASMFC in its adoption of catch limits and subsequent adjustments, while protecting an important nursery for menhaden. This is a historic opportunity to invest in the future of our Atlantic fisheries and Amendment 3 would set a precedent for the management of other species nationally. Please adopt ecological reference points now by passing Section 2.6, Option E, which is based on the best available science, provides for the needs of predators, and is a commonsense way to manage this valuable public resource to the benefit of every Atlantic state from Maine to Florida. Sincerely, 1 U.S. Department of the Interior, U.S. Fish and Wildlife Service, and U.S. Department of Commerce, U.S. Census Bureau. 2011 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation. Page 1 of 14
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October 24, 2017 Megan Ware, Fishery Management Plan Coordinator Atlantic States Marine Fisheries Commission (ASMFC) 1050 North Highland Street, Suite 200 A-N Arlington, Virginia 22201 Re: Menhaden Amendment 3 Dear Ms. Ware, Director Beal, Chairman Ballou, and members of the Menhaden Management Board, As more than 180 organizations, businesses, and individuals representing hundreds of thousands of members, business patrons and communities in every Atlantic state, we support the immediate adoption of ecological reference points in Amendment 3 to the Interstate Fishery Management Plan for Atlantic Menhaden. Specifically, we support Section 2.6 “Option E: BERP Workgroup Continues to Develop Menhaden-Specific ERPs with Interim Use of 75% Target, 40% Threshold.” Atlantic menhaden play a vital role in the marine food web as forage fish that feed a multitude of species including gamefish like striped bass, bluefish, king mackerel, and tarpon; marine mammals such as whales, dolphins, and seals; as well as birds including osprey, bald eagles, common loons, and brown pelicans. As key prey for these and other species, Atlantic menhaden are a critical backbone for our coastal communities, and the many businesses and wildlife-viewing opportunities that they support on and off the water. Managing Atlantic menhaden through Option E prioritizes their role as forage fish, allowing the resource to continue to grow and increase in value to recreational fishing, commercial fishing, and wildlife and tourism businesses. In fact, with over 28 million resident and nonresident wildlife watchers generating over $17 billion for the Atlantic states, ecological management of menhaden can help to drive healthy marine ecosystems as well as robust economies.1 Amendment 3 should follow the best science available today. Option E represents the best available science and is most consistent with the Menhaden Management Board’s long-standing commitment to ecological management. Option E sets a target of 75% unfished biomass and a threshold of 40% unfished biomass, providing flexibility to the Board to manage to the target over time, while also managing the resource conservatively, combining the best features of Options C and D. Furthermore, Option E sets the Board up for long-term success, allowing for management of this resource towards a target, while limiting the potential of overfishing from an ecosystem perspective. Amendment 3 also presents an opportunity to protect The Chesapeake Bay through a catch cap on the active reduction fishery in those waters. We recommend ASMFC adopt “Option B: Cap Set At 51,000 mt” and “Sub-Option B: No Rollover of Unused Cap Permitted” to adjust the cap to better reflect recent landings, following a precedent set by ASMFC in its adoption of catch limits and subsequent adjustments, while protecting an important nursery for menhaden. This is a historic opportunity to invest in the future of our Atlantic fisheries and Amendment 3 would set a precedent for the management of other species nationally. Please adopt ecological reference points now by passing Section 2.6, Option E, which is based on the best available science, provides for the needs of predators, and is a commonsense way to manage this valuable public resource to the benefit of every Atlantic state from Maine to Florida. Sincerely,
1 U.S. Department of the Interior, U.S. Fish and Wildlife Service, and U.S. Department of Commerce, U.S. Census Bureau. 2011 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation.
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CALIFORNIA Candace Crespi Campaign Director Oceanic Preservation Society Cassie Burdyshaw Advocacy & Policy Director Turtle Island Restoration Network CONNECTICUT Eileen Fielding Executive Director Farmington River Watershed Association Kris Rowe Owner Kristofer Rowe Photography Katie Cubina Senior Vice President for Mission Programs Mystic Aquarium Kevin Zak President Naugatuck River Revival Group Mary Pelletier Founding Director Park Watershed Bill Lucey Long Island Soundkeeper Save the Sound Patrick Comins Executive Director The Connecticut Audubon Society
DISTRICT OF COLUMBIA Brendan Mysliwiec Associate Director of Government Relations American Rivers John Hocevar Oceans Campaign Director Greenpeace USA Michael Gravitz Director of Policy and Legislation Marine Conservation Institute Karen Hyun Director of Water and Coastal Policy National Audubon Society Jim Lyon Vice President for Conservation Policy National Wildlife Foundation Brad Sewell Senior Attorney Natural Resources Defense Council Lora Snyder Campaign Director Oceana Dean Naujoks Riverkeeper Potomac Riverkeeper Jeff Kelble President Potomac Riverkeeper Network
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Peter Baker Director The Pew Charitable Trusts DELAWARE Brenna Goggin Director of Advocacy Delaware Nature Society Rich King President Delaware Surf Fishing Deb Schultz Joanne Cabry Tom Brett Progressive Democrats of Sussex County FLORIDA Capt. Steve Friedman Owner A Fishing Guide Charters Hannah Medd Presiden American Shark Conservancy Mike Conneen Executive Director Anglers for Conservation Dylan Hansen Founder/Filmmaker Balance for Earth Capt. Xavier Figueredo Owner Bay and Reef Company
Grayson Kyte Owner Bwana Baits Capt. Mike Conner Owner Capt. Mike Conner Fishing Stephen Gyland Owner Cod and Capers Seafood Capt. Dan Prochak Owner Cutlass Crew Fishing Charters Dennis Long Owner Dennis Long Painting Services LLC Dominic Agostini Owner Dominic Agostini Photography Steven Lewandowski Vice President Down Under Dive Club Derek June Owner DRJ Home Improvement Capt. Jon Reynolds Owner Drop Back Charters South Atlantic Fishing Environmentalists
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Capt. Mike Newman Owner Dykoke Charters Alex Pardo Owner El Pirate Boatworks Anne Burkholder Trustee Eltrose Farms Capt. Chuck Gleichmann President Flagler Sportfishing Club Florida Bay Forever Florida Forage Fish Coalition Officers and Directors Florida Sport Fishing Association Manley Fuller President Florida Wildlife Federation Skip Clement Owner/Publisher Fly Life Magazine Nikole Heath Social Media Director and Event Coordinator Force-E Scuba Centers Capt. Glynn Austin Owner Going Coastal Charters
Travis Moore Chief Fisheries Scientist Gray FishTag Research Capt. Carlos Jimenez Owner Gringo Fishing Charters Heather Crooks Owner Heather Crooks Recruiting, LLC Chris Peterson President and Owner Hell's Bay Boatworks Marty Baum Executive Director/Riverkeeper Indian Riverkeeper Jason Schratwieser Conservation Director International Game Fish Foundation Colin Hutton Owner Jewelwing Photography Jim Abernethy Owner Jim Abernethy's Scuba Adventures Stan Mihalecz President Jupiter Drift Divers Capt. Justin Rieger Owner Just-IN-Time Fishing Charters
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Alex Gorichky Owner Local Line's Guide Service Matt Cariseo Owner Lox River Skiffs Alex Pardo Manager LP Marine Services Kyle Rossin Co Founder/CEO Keith Rossin Co Founder/DO MANG Leesa Souto, Ph.D. Executive Director Marine Resources Council Tom Van Horn Captain Mosquito Coast Fishing Charters Billy Gibson Owner/Operator Motorized Kayak Adventures of the Treasure Coast Terry Gibson Principal North Swell Media, LLC Capt. Mike Newman Owner Octopus Marine Services Ed Tichenor Executive Director Palm Beach County Reef Rescue
Debbie Livingston Owner Paradise Accounting Services Inc. Patricia Miles HR Manager Personal Correspondence Capt. Pete Frezza Owner Peter Frezza Charters Rodney Smith Owner Rodney Smith Media Mitch Roffer, Ph.D. Owner ROFFS Fish Forecasting Service, Inc. J. Bruce Neill, Ph.D. Executive Director Sanibel Sea School Angela Smith President Shark Team One Brett Fitzgerald Executive Director Snook and Gamefish Foundation Nikole Heath Vice President South Florida Underwater Photography Society
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Matt Heyden Conservation Chair, Treasurer Space Coast Audubon Matt Cariseo Manager Sport Port Docking Systems Adam Birdwell Owner Starfish Scuba Lisa Miceli Owner Stoked On Salt James Bohrer President Stuart Rod and Reel Fishing Club Tim Goodwin Owner T&A Jigs Nancy Hull Owner The Brainery Bill Jacobs President Treasure Coast Hunting and Fishing Club Walt Stearns Owner Underwater Journal Mike Casale Past President Upper Keys Fishing Club
Walt Stearns Owner Walt Stearns Photography Tom Twyford President West Palm Beach Fishing Club Jim Abernethy Executive Director and Founder WildlifeVOICE GEORGIA Mike Worley President and CEO Georgia Wildlife Federation Capt. Scott Wagner Owner Savannah Fly Fishing Charters LOUISIANA Cynthia Sarthou Executive Director Gulf Restoration Network MASSACHUSETTS Andrew Fisk Executive Director Connecticut River Conservancy Megan Herzog Staff Attorney Conservation Law Foundation
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John Duane Owner Down Cape Realty Brian Kelder Restoration Program Manager Ipswich River Watershed Association Pine duBois Executive Director Jones River Watershed Association, Inc Chuck Anastas Chair, Board of Directors Massachusetts League of Environmental Voters Patrick Herron Executive Director Mystic River Watershed Association Rob Moir, Ph.D. Executive Director Ocean River Institute Thomas S. Kirk VP Board of Directors Red Lily Pond Project Assn., Inc. MARYLAND Chris Moore Senior Scientist Chesapeake Bay Foundation Chris Karwacki Fly Fishing Guide Chesapeake On The Fly: Fly Fishing & Light Tackle Charters
Mark Eustis Managing Director Grey Owl Analytics Jared Mott Conservation Director Izaak Walton League of America Kevin Josenhans Professional Fishing Guide Josenhans Fly Fishing Kurt R. Schwarz Conservation Chair Maryland Ornithological Society John McFalls President Ocean Pines Anglers Mark Eustis Director Stars & Stripers Fly Fishing Brent Walls Riverkeeper Upper Potomac Riverkeeper MAINE Zack Klyver Lead Naturalist Bar Harbor Whale Watch Roger Fleming Attorney Earthjustice
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NORTH CAROLINA Heather Hahn Executive Director Audubon North Carolina Larry Baldwin Executive Director Coastal Carolina Riverwatch Andy Wood Director Coastal Plain Conservation Group Larry Baldwin Executive Director Crystal Coast Waterkeeper Tim Gestwicki CEO North Carolina Wildlife Federation Jennifer Alligood Pamlico Albemarle Wildlife Conservationists John R. Spruill Director Spruill Farm Conservation Project Captain Tom Roller Owner and Guide WaterDog Guide Service Larry Baldwin Executive Director White Oak-New Riverkeeper Alliance
NEW HAMPSHIRE Derek Owen President Citizens for a Future NH Caroline Snyder, Ph.D. President Citizens for Sludge-Free Land Carol Foss Senior Advisor for Science and Policy New Hampshire Audubon James Glover President NH Animal Rights League Sr. Lucille Thibodeau Writer-In-Residence Rivier College Jim Chase President Seacoast Science Center Linda Dionne President Voices of Wildlife in NH NEW JERSEY Shawn Heinrichs Founder Blue Sphere Foundation Fred Akers River Administrator Great Egg Harbor National Scenic and Recreational River Council
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Jodi Jamieson Project Manager Hackensack Riverkeeper Heather Fenyk President Lower Raritan Watershed Partnership New Jersey Audubon Emile DeVito, Ph.D. Manager of Science and Stewardship New Jersey Conservation Foundation Debbie Mans, Executive Director Peter Cangeloso, Captain USCG NY/NJ Baykeeper NEW YORK Atlantic Beach Rod & Gun Club Brooklyn Urban Anglers Association Coastal Research and Education Society of Long Island Paul DeOrsay Executive Director Friends of the Bay Gateway Striper Club Paul L. Sieswerda President Gotham Whale Long Island Flyrodders
Debra O'Kane President North Fork Audubon Society Debra O'Kane Program Director North Fork Environmental Council Rob Weltner President Operation SPLASH Sean O'Neill Executive Director Peconic Baykeeper, Inc. River Bay Outfitters Salty Flyrodders of New York Seatuck Environmental Association Jamie Pollack Executive Director Shark Angels Daniel E. Estrin General Counsel & Advocacy Director Waterkeeper Alliance PENNSYLVANIA John Pedrick President Delaware River Fishermen's Association Ted Evgeniadis Riverkeeper Lower Susquehanna Riverkeeper
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Melinda Hughes President and Cofounder Nature Abounds Ezra Thrush Campaign Manager PennFuture Shane Morgan Watershed Coordinator White Clay Watershed Association Todd Pride Lead Management & Training Coach Mid-Atlantic Youth Anglers & Outdoors Program RHODE ISLAND Meg Kerr Director of Policy Audubon Society of RI Greg Gerritt Founder, Watershed Steward Friends of the Moshassuck Alex Duryea Sustainability Coordinator Providence College Katherine Brown Consultant Rockbridge Farm Consulting Save The Bay Alicia Lehrer Executive Director Woonasquatucket River Watershed Council
SOUTH CAROLINA Josh Finnigan Owner Back Bay Rentals Greg Peralta Principal CaptGregP.com Scott Snider Principal Half Moon Productions Deas Manning Owner Island Watersports Mick Fisher Partner Resource Solutions Ben Gregg Executive Director South Carolina Wildlife Federation Jim Moring President The Commonwealth Co., LLC Ross Rames Partner Urology Associates VIRGINIA Catherine Kilduff Senior Attorney Center for Biological Diversity
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Steven Epstein Founder Chesapeake Bay Defenders Thomas A. Miller Board Member, Legislative Affairs Friends of the Rivers of Virginia Karen W. Forget Executive Director Lynnhaven River NOW James Shelton Legislative Chair Richmond Audubon Mark Frondorf Riverkeeper Shenandoah Riverkeeper Timothy P. O'Brien President Tycoon Tackle, Inc. John Bello Chairman of the Board Virginia Saltwater Sportfishing Association Ken Hinman President Wild Oceans
